In its comments to FDA, ABA called on the Agency to rescind, stay or at the very least consider less burdensome options for declaring added sugar labeling and Daily Reference Value (DRV) requirements that were part of the Nutrition Facts Label (NFL) regulations. ABA noted that bakers are impacted more than any other food sector in dealing myriad label changes, each requiring separate record keeping requirements and generation of new records. ABA also took the opportunity to re-emphasize the need for additional NFL implementation time asking, as it has in previous comments, for five years until July 26, 2021 to comply.